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2013-11-12_REVISION - C1981014
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2013-11-12_REVISION - C1981014
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Entry Properties
Last modified
8/24/2016 5:37:13 PM
Creation date
11/14/2013 9:00:11 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
REVISION
Doc Date
11/12/2013
Doc Name
Additional Detail Responses (10/18/13)
From
Energy Fuels Coal, Inc
To
DRMS
Type & Sequence
TR39
Email Name
DAB
DIH
RDZ
Media Type
D
Archive
No
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corresponding to "25, 16 and 10 acres respectively." Thus, the size of the RA's has nothing to do with <br />calculating the weighted average value, only the size of the reclaimed parcel being compared is <br />considered. <br />In connection with the calculation of the final bond release revegetation success criteria, EFCI proposes to <br />use the following weighted average approach based upon the acreage of the reclamation areas. For the <br />Vento Portal reclamation parcel, a weighted average factor of 10.22/68.31 (0.1496); for the Corley Portal <br />reclamation parcel, a weighted average factor of 11.71/68.31 (0.1714) and for the Refuse Pile reclamation <br />parcel, a weighted average factor of 46.38/68.31 (0.6790) will be used. Application of these weighted <br />average factors would mean that for the cover and production values from the Vento Portal reclamation <br />and New Portal RA would be multiplied by a factor of 0.1496; the cover and production values from the <br />Corley Portal and Old Portal RA (Reference Plot B) would be multiplied by a factor of 0.1714 and the <br />cover and production data from the Refuse Pile reclamation and RA would be multiplied by a factor of <br />0.6790. The data from these three reclaimed areas and the RA's would then be summed into a single <br />value. <br />The final revegetation success criteria for the reclaimed areas will be calculated based upon the data <br />collected from the Vento Portal reclamation parcel, the Corley Portal reclamation parcel and the Refuse <br />Pile reclamation parcel using the approach contained in Example 2, found on pages 23 -24 of the Bond <br />Release Guideline, while the final revegetation success criteria from the three RA's will be calculated <br />based upon these weighting value factors and following the approach contained in Example 3, found on <br />page 25 -26 of the Bond Release Guideline. <br />Sample adequacy of the three reclaimed sites, and three undisturbed RA's will be calculated <br />independently by site, and for each reclaimed area, either sample adequacy will be achieved according to <br />the formula found using either the sample adequacy equation found in the Regulations or the Bond <br />Release Guideline or until the required sample size associated with the "reverse null hypothesis" is <br />satisfied. <br />Concern 3. The revised page 2.04.10 -5 (amended Oct, 2013) refers to Map 16 for the location of the <br />proposed Pinion - Juniper reference area. Map 16, previously submitted, May 31, 2011 as part of the TR <br />39 application package was unapprovable as submitted. Information depicting the pre- mining vegetation <br />types was extremely faint, rendering the map unacceptable. Please remove this reference. Please refer to <br />the Exhibit 27, figures that were previously included in the Division's proposed decision form. <br />Response: Map 16 has been revised showing the locations of the current RA's as determined by GPS <br />surveys of these sites, using the previously placed metal t post corners. In addition, Map 1, Southfield <br />Mine - Portal Reclamation Map, (confined to TR -39) has been modified and is now called revised Map 1, <br />Southfield Mine - Reclamation Map. This original map was previously submitted as a map in Exhibit 27 <br />and has been revised as recommended by the CDRMS, showing the revised location of the New Portal <br />Reference Area from which all previous disturbance has been excluded. <br />
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